GM Wallet Privacy Policy

This GM Wallet Privacy Policy (this “Policy”) is issued by Good Morning Technology, LLC (“Good Morning Technology,” “we,” “us,” “our,” the “Company,” or “GM Wallet”) and applies to information processing activities in connection with your access to, download, installation, registration for, and use of the GM Wallet application, websites, plugins, interfaces, GM Gas, cloud backup notices, third-party service integrations, on-chain interaction portals, and any other related features or services.

GM Wallet is a non-custodial wallet. We do not hold, control, or custody your private keys, seed phrases, passwords, signing authority, or on-chain assets. This Policy explains how we process information relating to you when providing the Services and how we protect your privacy.

Please read this Policy carefully and make sure you fully understand it before using GM Wallet or GM Gas. If you do not agree to any provision of this Policy, you must immediately cease accessing or using GM Wallet and related services.

1. Relationship with the Terms of Use and GM Gas Terms

1. This Policy, together with the GM Wallet Terms of Use and Disclaimer, the GM Gas Terms of Use, supplemental terms, risk notices, third-party service descriptions, page notices, and campaign rules, forms part of the complete rule framework between you and Good Morning Technology, LLC with respect to GM Wallet and related services.
2. This Policy describes only how GM Wallet and GM Gas process information within the scope of their own services. When you interact through GM Wallet with blockchain networks, DApps, smart contracts, third-party Swap, Bridge, Perpetuals, Fiat On-ramp/Off-ramp services, node services, RPC services, cloud services, stablecoin issuers, or other Third-Party Services, such third parties may process your information in accordance with their own privacy policies. Such third-party information processing activities are outside the control of GM Wallet.
3. If there is any inconsistency between this Policy and a specific feature page, third-party service description, or GM Gas-specific term, the provision that is more specific and more applicable to the relevant feature shall prevail. However, no provision shall be construed to diminish the non-custodial nature of GM Wallet, the user’s sole responsibility for on-chain interactions, the independent responsibility of Third-Party Services, or the public and transparent nature of blockchain networks.

2. Our Core Privacy Principles

1. Data minimization. We process information only to the extent necessary to provide, maintain, protect, and improve GM Wallet, GM Gas, and related services, and we do not collect data that is unrelated to or unnecessary for the Services.
2. Non-custodial principle. We do not collect, store, or custody your private keys, seed phrases, recovery phrases, cloud backup decryption passwords, or any sensitive credentials that can directly control your on-chain assets.
3. No user address profiling. Unless expressly stated in this Policy or mandatorily required by applicable law, we do not unnecessarily bind user data to wallet addresses, and we do not create user address profiles, asset profiles, fund flow profiles, transaction preference profiles, or on-chain relationship profiles for commercial purposes.
4. No active association of users’ on-chain relationships. We do not actively analyze, infer, or establish ownership relationships among your different wallet addresses, and we do not actively analyze your on-chain sources of funds, destinations of funds, counterparty relationships, social relationships, asset association relationships, or address clusters for advertising, marketing, or commercial profiling purposes.
5. Single-address isolation principle. For address-related services such as address data queries, balance display, transaction history display, and risk notices, we endeavor to process data on a single-address basis and do not merge, cluster, or persistently associate multiple addresses for the purpose of creating cross-address user profiles.
6. No advertising use. We do not use your wallet addresses, on-chain transaction data, GM Gas usage data, device data, or other user data for targeted advertising, third-party ad delivery, advertising profiles, or ad retargeting.
7. No sale of personal information. We do not sell or rent your personal information and do not sell, rent, or share your user data with third parties for marketing purposes.
8. Transparency and control. We endeavor to explain clearly and reasonably what information we process, why we process it, how we protect it, and how you may exercise your applicable rights.

3. Information We May Process

The information we process depends on the features you actually use. As a non-custodial wallet, the core wallet functions of GM Wallet generally do not require you to provide your real name, identity documents, residential address, bank account, or other traditional financial account information, unless you voluntarily submit such information or a third party separately requires it when you use a Third-Party Service.

3.1 Information You Voluntarily Provide

When you contact customer support, submit feedback, participate in campaigns, make a claim, send emails, complete forms, or otherwise communicate with us, you may voluntarily provide us with information including:

1. contact information, such as email address, Telegram account, social media account, or other contact details you voluntarily provide;
2. customer support and communication content, such as issue descriptions, screenshots, logs, transaction hashes, wallet addresses, device information, error feedback, claim materials, or other content you voluntarily submit;
3. campaign participation information, such as campaign registration information, reward claim information, eligibility verification information, or necessary information required by campaign rules;
4. legal, compliance, or dispute resolution information, such as supporting documents, statements, requests, complaints, or other materials you voluntarily submit.

3.2 Wallet and On-Chain Information

To display balances, transaction history, token information, NFTs, on-chain status, gas estimates, transaction status, risk notices, or other wallet features, we may process the following information:

1. wallet addresses that you create, import, connect, or query within the application;
2. chain IDs, network types, token contract addresses, transaction hashes, block heights, transaction status, gas estimates, gas consumption, approval status, smart contract interaction information, and other public on-chain data;
3. addresses, transaction hashes, screenshots, error logs, or on-chain interaction information that you voluntarily submit to customer support or for troubleshooting purposes.

The above on-chain information generally comes from public blockchain networks, nodes, RPC services, block explorers, or other public data sources. Our display or reading of such information does not make us the controller, custodian, or responsible party for the relevant assets, transactions, or on-chain projects.

3.3 Device, Network, and Technical Information

To ensure proper operation of the application, troubleshoot issues, maintain security, identify abnormal behavior, and improve the Services, we may process limited device and technical information, including:

1. device type, operating system version, application version, language settings, time zone, device identifiers, or installation identifiers;
2. IP address, network status, request time, error logs, crash logs, performance data, and security logs;
3. feature usage status, page loading status, API call status, system abnormalities, risk-control interception records, and necessary diagnostic information.

We do not collect such information for advertising profiling or marketing purposes. We also do not unnecessarily and persistently bind device information to wallet addresses for the purpose of creating user on-chain identity profiles.

3.4 GM Gas-Related Information

When you use GM Gas, we may process the following information to complete Credit accounting, process Gas Sponsorship requests, provide transaction submission assistance, conduct risk control, maintain service records, and resolve disputes:

1. account identifiers, top-up records, Membership Consumption Credit balances, Credit consumption records, and service request records;
2. chain IDs, transaction hashes, gas estimates, gas consumption, transaction status, request time, failure reasons, system records, and third-party service return status;
3. risk labels, abnormal request records, customer support claim records, and explanatory materials voluntarily submitted by you.

GM Gas-related data is used only for service performance, Credit accounting, security risk control, compliance, dispute resolution, and service improvement. It is not used for advertising purposes, is not used to create user address profiles, and does not mean that we custody or control your on-chain assets.

3.5 Cloud Backup-Related Information

GM Wallet may prompt or support cloud backup features based on mobile device manufacturers, operating systems, or third-party cloud storage services, such as iCloud, Google Cloud, Google Drive, or other cloud services.

Cloud backup services are independently provided by the relevant mobile device manufacturers, operating system providers, or cloud service providers. GM Wallet does not operate, control, or manage such cloud services, does not store your cloud account password, does not store cloud backup decryption passwords, and does not provide private key, seed phrase, or cloud account recovery services.

You should independently read and understand the privacy policies, terms of service, and security mechanisms of the relevant cloud service providers, and independently protect your cloud accounts, device passwords, two-factor authentication, and recovery credentials.

4. What We Do Not Do

Unless mandatorily required by applicable law, voluntarily authorized by you, necessary to handle security incidents or disputes, or expressly stated in this Policy, we do not:

1. collect, store, or custody your private keys, seed phrases, recovery phrases, cloud backup decryption passwords, or any credentials that can directly control on-chain assets;
2. actively bind your real identity to wallet addresses where such binding is unnecessary;
3. create user address profiles, asset profiles, transaction profiles, risk preference profiles, or on-chain relationship profiles for advertising, marketing, or commercial profiling purposes;
4. actively analyze, infer, or establish ownership relationships among multiple addresses of yours;
5. actively analyze the sources of funds, destinations of funds, counterparties, on-chain social relationships, or address clusters of your addresses for commercial purposes;
6. use your wallet addresses, on-chain transaction data, GM Gas usage data, or device data for targeted advertising, ad retargeting, or third-party ad delivery;
7. sell or rent your personal information to third parties;
8. sell, rent, or share user address query data, identity-address mapping, or address association profiles generated from address data services with third parties for advertising, marketing, or commercial profiling purposes;
9. collect unnecessary data unrelated to GM Wallet, GM Gas, or related services;
10. ask you to provide private keys, seed phrases, verification codes, remote access permissions, or other sensitive information that can directly control your assets.

5. Address Data Isolation and On-Chain Data Processing

1. GM Wallet may provide balance display, transaction history, token display, risk notices, gas estimates, transaction status display, or other address data services. In designing such services, we endeavor to process data on a single-address basis.
2. Single-address isolation means that, in ordinary product features, we endeavor to query, display, and process data by individual address. We do not actively combine multiple addresses for the purpose of creating a complete on-chain profile of a user, do not actively infer whether multiple addresses belong to the same user, and do not actively analyze funding relationships, transaction relationships, or social relationships among user addresses for advertising or commercial profiling purposes.
3. To provide address data services, we may need to access blockchain nodes, RPC services, block explorers, indexing services, or other infrastructure. Such infrastructure may technically receive an individual address, transaction hash, chain ID, IP address, request time, or other necessary request parameters. We will use reasonable efforts to reduce unnecessary data exposure, but we cannot guarantee that third-party infrastructure will not independently process or infer information based on its own systems, logs, or public on-chain data.
4. We do not actively provide third parties with mappings between user identity and wallet addresses, and we do not actively provide third parties with user address profiles or address relationship graphs created by GM Wallet for advertising, marketing, or commercial purposes.
5. Where necessary for security risk control, anti-fraud, system protection, dispute resolution, compliance requirements, sanctions screening, or legal proceedings, we may process specific addresses, transaction hashes, risk labels, or related records within the minimum necessary scope. Such processing should not be understood as routine profiling or commercial analysis of a user’s entire on-chain relationships.

6. How We Use Information

We may process necessary information for the following purposes:

1. to provide, maintain, and improve GM Wallet, GM Gas, and related services;
2. to display wallet balances, transaction records, token information, NFTs, gas estimates, transaction status, and public on-chain data;
3. to process GM Gas top-ups, Membership Consumption Credit accounting, Gas Sponsorship requests, Credit deduction records, abnormal deduction claims, and service records;
4. to provide customer support, troubleshoot issues, fix errors, analyze logs, and process user feedback;
5. to maintain system security, identify abnormal behavior, and prevent fraud, phishing, attacks, subsidy abuse, malicious requests, exploitation of system vulnerabilities, or other risks;
6. to provide risk notices, malicious address warnings, phishing link alerts, transaction simulations, approval risk notices, or other security assistance features;
7. to comply with applicable laws, regulatory requirements, sanctions, export controls, anti-money laundering, counter-terrorist financing, judicial, law enforcement, or compliance obligations;
8. to handle complaints, disputes, arbitration, litigation, law enforcement assistance, audits, or internal compliance reviews;
9. to protect the lawful rights and interests of GM Wallet, GM Gas, Good Morning Technology, LLC, users, partners, and third parties;
10. to conduct service performance statistics, fault analysis, product security improvement, and user experience optimization without personal identification or address profiling.

7. How We Share or Disclose Information

We value user privacy. We do not sell your personal information and do not share your personal information for advertising or marketing purposes. We share or disclose information only within the following necessary scope:

1. With your voluntary authorization or explicit request. For example, where you actively request that we assist with troubleshooting a transaction, handle a customer support request, process campaign participation, or review a claim.
2. With service providers necessary to provide the Services. We may provide necessary information, within the minimum necessary scope, to cloud service providers, node service providers, RPC service providers, security service providers, customer support systems, audit institutions, data processing service providers, payment service providers, technical support providers, or other service providers. Such service providers should process information only for the purpose of providing the relevant services and must not use the information for their own advertising, marketing, or unrelated purposes.
3. For security and risk-control purposes. To prevent fraud, attacks, abuse, vulnerability exploitation, illegal activities, sanctions evasion, or other security risks, we may process or share relevant risk information where necessary.
4. For legal, regulatory, judicial, or law enforcement requirements. If we reasonably believe that applicable law, regulatory requirements, court orders, arbitration proceedings, law enforcement requests, sanctions rules, export control rules, or other legal proceedings require disclosure, we may disclose necessary information in accordance with law.
5. To protect lawful rights and interests. Where necessary to protect the lawful rights and interests, system security, intellectual property, trade secrets, or to prevent material harm to Good Morning Technology, LLC, GM Wallet, GM Gas, users, partners, or third parties, we may disclose necessary information.
6. Corporate transactions. In the event of a merger, reorganization, acquisition, financing, asset transfer, business transfer, change of control, or similar transaction, we may transfer service-related information to the extent reasonably necessary, provided that the recipient remains bound by this Policy or privacy commitments no less protective than this Policy.

8. Third-Party Services and External Projects

1. GM Wallet may integrate, display, link to, or invoke Third-Party Services, including without limitation Swap, Bridge, Perpetuals, Fiat On-ramp/Off-ramp, DApps, smart contracts, stablecoin issuers, nodes, RPC services, block explorers, market data services, risk detection services, cloud services, or other external resources.
2. When you use Third-Party Services through GM Wallet, access third-party pages, connect to DApps, invoke smart contracts, conduct Swap, Bridge, Perpetuals, fiat on-ramp or off-ramp, or engage in other on-chain interactions, such third parties may process your information in accordance with their own privacy policies, terms of service, Cookie policies, KYC/AML policies, or compliance rules.
3. GM Wallet does not control the information processing activities of Third-Party Services and shall not be liable for third-party privacy policies, data security, information use, KYC reviews, account restrictions, data sharing, or any third-party processing results.
4. Before using any Third-Party Service, you should independently read and understand that third party’s privacy policy, user agreement, risk disclosure, and applicable legal requirements, and independently decide whether to continue using such service.
5. GM Wallet’s display of any third-party name, logo, portal, link, interface, quotation, data, or service does not constitute any guarantee, recommendation, recognition, or endorsement by GM Wallet of that third party’s privacy practices, security level, compliance status, or service results.

9. Public Nature and Non-Deletion of Blockchain Data

1. You understand and agree that blockchain networks are generally public, transparent, queryable, replicable, analyzable, immutable, and difficult to delete.
2. Your wallet addresses, transaction hashes, transaction amounts, token holdings, NFTs, approval records, smart contract interactions, timestamps, gas consumption, and other on-chain information may be viewed, copied, retained, analyzed, or associated by any person through block explorers, nodes, RPC services, data analytics tools, third-party indexing services, or other public channels.
3. GM Wallet cannot control the degree of information disclosure on public blockchains, and cannot delete, modify, hide, or withdraw data that has already been recorded on-chain.
4. Even if GM Wallet does not actively create user address profiles, third parties may still analyze, label, associate, or profile addresses based on public on-chain data, information voluntarily disclosed by users, counterparty information, social media information, exchange information, DApp information, or other sources. Such activities are not controlled by GM Wallet.
5. You should prudently manage your wallet addresses, signature activities, on-chain transactions, DApp connections, and public disclosures, and avoid unnecessarily associating your personal identity with on-chain addresses.

10. Cookies, SDKs, and Similar Technologies

1. GM Wallet websites or related pages may use Cookies, local storage, SDKs, logging tools, or similar technologies to enable basic functions, maintain service stability, improve security, analyze crash causes, or improve user experience.
2. We do not use such technologies for third-party ad delivery, targeted advertising, ad retargeting, or advertising profiles.
3. If a specific third-party SDK or service provider participates in providing necessary functions, we will endeavor to select service providers that meet security and privacy requirements and restrict them to processing information only to the extent necessary to achieve the service purpose.
4. You may manage Cookies, notifications, permissions, or similar technologies through your browser, device system, or application permission settings. However, disabling certain permissions may affect the normal use of some functions.

11. Data Retention Period

1. We retain information only for the period necessary to achieve the purposes described in this Policy, perform legal obligations, resolve disputes, maintain security, complete audits, or protect lawful rights and interests.
2. Customer support records, claim records, GM Gas Credit records, transaction troubleshooting records, security logs, compliance records, and dispute resolution records may be retained for a reasonable period based on business needs, legal requirements, audit requirements, or dispute resolution needs.
3. For technical logs generated from address query, balance display, transaction status display, and similar services, we will endeavor to limit the scope and retention period and will not retain or associate such logs long-term for advertising profiling or commercial address profiling purposes.
4. For public blockchain data, due to its public, immutable, and distributedly replicated nature, we cannot delete, modify, or control information already recorded on-chain.

12. Data Security

1. We will adopt commercially reasonable technical and administrative measures to protect information security, including without limitation access controls, permission management, encrypted transmission, log audits, security monitoring, vulnerability remediation, anomaly detection, internal management policies, and necessary security assessments.
2. We will restrict access to user information by employees, contractors, service providers, or partners and permit access only to the extent necessary for performing duties or providing services.
3. You understand that no internet system, Blockchain Network, wallet software, cloud service, communication network, or data transmission method can be guaranteed to be absolutely secure. To the extent permitted by law, we shall not be liable for risks caused by hacking, malware, phishing, device theft, system vulnerabilities, Third-Party Service failures, on-chain attacks, user error, or other causes not reasonably controllable by us.
4. You should independently adopt security measures to protect your devices, applications, private keys, seed phrases, passwords, cloud accounts, verification codes, network environment, and signing authority. No customer support representative, community administrator, or staff member will ask you for private keys, seed phrases, passwords, verification codes, or remote access permissions.

13. Your Rights

Depending on applicable law, you may have rights to access, correct, delete, restrict processing of, withdraw consent to processing of, port, object to processing of, complain about, or exercise other rights in relation to your personal information.

You may submit requests through info@gmwallet.app or other official contact methods published by us. To protect account and information security, we may need to verify your identity or the content of your request. We will process your request to the extent permitted by applicable law and technically feasible.

Please note:

1. For private keys, seed phrases, on-chain assets, or on-chain transactions in a non-custodial wallet, we cannot recover, modify, delete, or revoke them on your behalf;
2. For information already recorded on public blockchains, we cannot delete, modify, or hide it;
3. For information necessary to perform legal obligations, security risk control, audits, dispute resolution, anti-fraud, sanctions compliance, or protection of lawful rights and interests, we may continue to retain or process such information in accordance with law;
4. If you withdraw certain authorizations or request deletion of certain necessary information, some functions may no longer be available.

14. Minors

GM Wallet and GM Gas are not directed to users who have not reached the legal age of majority in their jurisdiction or who do not have full legal capacity. Minors may not use GM Wallet or GM Gas without the consent of their guardian and where permitted by applicable law.

If we become aware that a minor has provided personal information to us in a manner that does not comply with applicable law or this Policy, we will take reasonable measures in accordance with applicable law and technical feasibility.

15. International Transfers

Because GM Wallet and GM Gas may provide services to users globally, we may process, store, or transfer necessary information in jurisdictions outside your country or region. The data protection laws of such jurisdictions may differ from those in your location.

Where cross-border processing or transfer occurs, we will endeavor to take reasonable protective measures in accordance with applicable law to ensure that information processing is consistent with the purposes and protection standards described in this Policy.

16. Updates to This Policy

We may update this Policy from time to time based on business changes, product adjustments, technical updates, laws and regulations, regulatory requirements, or security needs.

The updated Policy will be published through in-app notices, website announcements, pop-ups, version updates, electronic notices, or other reasonable methods. The updated Policy shall take effect upon publication or on the effective date stated in the relevant notice.

If you do not agree to the updated Policy, you must stop using GM Wallet, GM Gas, and related services. Your continued use of the relevant services after the Policy is updated shall be deemed your acknowledgement that you have read, understood, and accepted the updated Policy.

17. Entire Policy and Language

This Policy, together with the GM Wallet Terms of Use and Disclaimer, the GM Gas Terms of Use, supplemental terms, risk notices, third-party service descriptions, and page notices referenced herein, forms part of GM Wallet’s privacy protection rules.

The English version of this Policy shall prevail. We may provide Chinese or other language versions for users’ convenience, or identify privacy notices most relevant to specific features on related pages, functions, pop-ups, or notices for reference. Such translations, summaries, labels, or notices are for reference only and shall not constitute any severance, amendment, supplement, replacement, or separate agreement to this Policy.

In the event of any inconsistency, ambiguity, or conflict among different language versions, or between summaries, page notices, feature descriptions, and the complete English version, the complete English version shall prevail, unless otherwise mandatorily required by applicable law.

18. Contact Information

If you have any questions, requests, complaints, or suggestions regarding this Policy, GM Wallet, GM Gas, or your privacy rights, you may contact us at:

info@gmwallet.app

Please note that no customer support representative, community administrator, or staff member will ask you for private keys, seed phrases, passwords, verification codes, or remote access permissions. You should verify the source of information through official channels and remain vigilant against fraud.

Version: V1.0
Effective Date: 05 June 2026
Contact: info@gmwallet.app